Is a lender responsible for what an AI or agency says on collection calls?

Accountability stays with the regulated entity

RBI's guidelines on recovery agents and its directions on outsourcing of financial services say a regulated entity cannot outsource its responsibility to customers. Banks, NBFCs, housing finance companies and other regulated entities remain answerable for harassment, privacy breaches or misconduct by anyone collecting on their behalf. RBI has in the past restricted lenders from using outside recovery agents after serious misconduct.

For digital lending, RBI's rules add that lending service providers act under the lender's oversight, and borrowers must be told who will contact them about recovery. An AI platform making collection calls sits inside that same chain of accountability.

What a lender must control in an AI deployment

• —Script approval by compliance before launch and after every change.
• —Hard limits: 8 am to 7 pm, attempt caps, polite language, no threats.
• —Identity checks before discussing the loan, to avoid disclosure to third parties.
• —A grievance route: disputes and hardship requests captured and flagged for staff to call back.
• —Recordings and transcripts kept for audits and complaint handling.

Contract terms with the vendor

Treat the AI platform as an outsourced service provider: put data protection, confidentiality, audit access and incident reporting into the contract. Under the DPDP Act 2023 the lender is the data fiduciary and the platform a data processor, which should also be written down.

How Outpero fits

Outpero gives lenders a recording, transcript, summary and sentiment for each call, a configurable calling window and custom fields such as promise-to-pay date and reason for delay. Script approval, monitoring and grievance handling remain with the lender.